Atkins v. Virginia
Atkins v. Virginia, 536 U.S. 304 (2002).
Facts: Defendant Atkins abducted a man from a convenience store and subsequently killed him. Defendant was charged first-degree murder. According to a clinical psychologist, Defendant had an IQ of 59, meaning he was "mildly mentally retarded."
Procedural History: Defendant was found guilty at trial and given the death penalty. Defendant appealed the verdict. The Appellate court and then the Virginia Supreme Court both upheld the death sentence, with Atkins appealing both decisions.
Arguments: Defendant argued that he is mentally handicapped and therefore executing him would be cruel and unusual punishment in violation of the Eighth Amendment.
Issue: Is it cruel and unusual to execute a mentally handicapped person and therefore a violation of the Eighth Amendment?
Holding: Yes, it is cruel and unusual punishment to execute a person who has less capacity to defend himself and communicate remorse to the jury.
Reasons: Unlike other provisions of the Constitution, the Eighth Amendment should be interpreted in light of "evolving standards of decency that mark the progress of a maturing society" and that current standards dictate that the mentally retarded shouldn't be executed. Execution of such people fails to promote the public policy purposes of capital punishment, so such executions would be a "purposeless and needless imposition of pain and suffering."
Judgment: Affirmed the conviction but reversed the sentence.